January 18, 2011

You might wonder if, and if so, why, healthcare providers who have been convicted of Medicare fraud are still practicing medicine, writing prescriptions, and billing health plans (except, presumably, Medicare). Well, it's a good question. Apparently such a conviction may not get a provider's NPI deactivated.

For several months the number of providers that appear on both the HHS Office of Inspector General's excluded providers list and the current National Plan and Provider Enumeration System (NPPES) have hovered around 2,700.* But for December the number jumped to 2,925. Of that number, more than 1,400 are physicians.

For the past several months, CMS has dropped only 400 to 500 providers each month for various reasons; not all dropped NPI records are due to fraud convictions. Interestingly, the December NPPES dropped more than 1,000 records, while still including more than 2,900 providers listed in the LEIE (List of Excluded Individuals/Entities), the federal database primarily of healthcare providers convicted of fraud or other crime, for patient neglect or abuse, felony controlled substance conviction, or whose licenses have been revoked, suspended or surrendered. A small number of providers are included on the list for less serious reasons, including refusal to provide required information to HHS, and default on a federal healthcare education loan. An inquiry sent to CMS requesting information on the matter has not been answered.

Each month, nearly 30,000 new records are added to the NPI database, primarily representing new healthcare providers. On average, 33,000 records are updated (by the providers themselves in nearly every case). The December NPPES database includes 3,277,833 healthcare provider records. All HIPAA-covered U.S. healthcare providers are required to obtain an NPI record. For all practical purposes, a physician's NPI number, along with a DEA number, is required to write a prescription because pharmacies generally require them. Theoretically, at least, if a pharmacy could not find a valid NPI number, it could refuse to fill the prescription.

CarePrecise compiles federal healthcare provider data for use in research, clinical trial provider pool development, fraud prevention and marketing. Clients include health plans, educational institutions, drug companies, marketers, law enforcement, health systems and individual providers.
_______* Source: CarePrecise research data. Methodology involves cross-referencing the two databases using proprietary algorithms to affix NPI numbers to providers in the fraud database; the fraud database (LEIE) does not include NPI numbers, making it difficult to track against practicing providers. Actual number of providers on both lists may be higher; the cross-referencing algorithm is used conservatively.